Date: 8/10/98 9:58 AM
Subject: Proposed Rule 102(e)(1)(ii) FILE S7-16-98
In the preparation of SEC related documents, often there are numerous people
involved in the preparation, review and audit of such documents. The proposed
rule would not punish those CPA's if the are in fact CPA's who are preparing the
documents who engaged in "Improper Professional Conduct". There are numerous
other licensed professionals such at attorneys who get involved with SEC realted
documents. The same standards must be held up to all parties involved.
All SEC related documents are audited and/or reviewed by senior management,
some of these people may or may not be LICENSED professionals. To hold a
selected group of people to standards withoud holding management to those same
standards would be a travisty. If the SEC wants to sponsor its own
certification and licensing standards that would be more appropriate than to
hold other professionals to standards that might jeopardize that profession.
Under the AICPA's Code of Professional Conduct these professionals would be
covered, sanctioned and possible removed from the practice of public accounting
If they were found to be in violation.
THE SEC should not be governing the public accounting profession. That should
be left to the AICPA.
Peter D. Rothman
Volt Information Sciences. Inc.
1600 Stewart Avenue
Suite 100
Westbury, New York 11590